Medical coding: an ICD primer |
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As a Certified Professional Coder, Health Policy Associate Meghan Basler supports Applied Policy's clients in navigating the intersection of regulatory compliance and the pragmatic application of medical coding.
This month, Meghan begins a new series on medical coding with an explanation of the ICD-10-CM, which comprises the more than 70,000 alphanumeric codes used for categorizing medical diagnoses and is integral to reimbursement in the United States’ healthcare system.
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The International Statistical Classification of Diseases and Related Health Problems, commonly known as the ICD, is a globally recognized system of medical data management. Developed, maintained, and copyrighted by the World Health Organization, the ICD offers a comprehensive framework for classifying diseases, medical conditions, and other health-related phenomena. In its tenth iteration, it is known as the ICD-10.
More than 114 countries use the ICD to monitor mortality (deaths) and morbidity (disease and injury). Beyond being an essential epidemiological tool, the ICD serves as the basis for healthcare planning, resource allocation, and health policy development in many nations.
In the United States, we are most familiar with the ICD-10-CM (International Classification of Diseases, Clinical Modification), a U.S.-specific adaptation of the ICD-10 which is essential for establishing and documenting the medical diagnoses that justify the clinical interventions for which healthcare providers bill.
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Discarded drug refund program moves forward
as CMS clarifies policies
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As Applied Policy reported in January, under Section 90004 of the Infrastructure Investment and Jobs Act which was passed in November 2021, manufacturers of drugs, including biosimilar biologic products, in single dose containers or single use packages which are separately payable under Medicare Part B are required to provide the Centers for Medicare & Medicaid Services (CMS) a refund for unused portions of specified drugs.
Although CMS adopted some requirements in connection with the discarded drug refund policy in the Calendar Year (CY) 2023 Physician Fee Schedule (PFS) final rule, until this summer the agency had not yet proposed specifics on certain provisions of the legislation including timelines for reports and the due date for initial payments.
The issuance of the CY 2024 Medicare PFS Notice of Proposed Rulemaking in August provided important clarifications. These included timelines for when the agency will issue key reports, as well as responses to specific concerns expressed by drug manufacturers and healthcare providers.
With Medicare Administrative Contractors issuing instructions on compliance and a final rule expected in the coming weeks, the program should soon be fully implemented.
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Applied Policy's latest rules summaries |
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On September 29, 2023, the Food and Drug Administration (FDA) released its highly anticipated proposed rule, Medical Devices; Laboratory Developed Tests. This proposed rule aims to clarify the categorization of In Vitro Diagnostics (IVDs) as medical devices under the Federal Food, Drug, and Cosmetic Act (FD&C Act), regardless of whether these IVDs are manufactured by laboratories or other entities.
A 60-day comment period is tentatively scheduled to close on December 26, 2023.
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On September 7, 2023, the U.S. Department of Health and Human Services (HHS), through its Office for Civil Rights (OCR), issued the Discrimination on the Basis of Disability in Health and Human Service Programs or Activities proposed rule. HHS also issued a fact sheet and press release on the proposed changes. The goal of the rule is to promote access to healthcare for persons with disabilities and prohibit discrimination on the basis of disability by recipients of financial assistance from HHS (“recipients”). The proposals would apply to all HHS programs and organizations that do business with HHS.
Comments on the proposed rule are due November 13, 2023.
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MACPAC holds September 2023 meeting |
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The Medicaid and CHIP Payment and Access Commission (MACPAC) held a virtual public meeting on September 21 and 22, 2023.
The meeting included sessions on denials and appeals in Medicaid managed care, a panel discussion on unwinding the continuous coverage requirement, and eligibility and enrollment for Medicare Savings Programs.
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The Medicare Payment Advisory Commission (MedPAC) held a virtual public meeting on September 7 and 8, 2023.
The meeting included the sessions on the context for Medicare payment policy, MedPAC’s work plan for Medicare Advantage (MA), standardizing benefits in MA, improving MedPAC’s estimate of MA coding intensity, Medicare’s Acute Care Hospital at Home program, and a primer on ambulatory surgical centers.
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Emma Hammer promoted to Senior Health Policy Associate |
Applied Policy has announced the promotion of Emma Hammer to Senior Health Policy Associate. A member of the Applied Policy team since 2021, Emma performs health policy research and analysis for a variety of healthcare clients, with a focus on the pharmaceutical sector. |
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Offering his congratulations, Applied Policy's COO John Voorhees observed that, "Emma's experience working at CMS while completing her degree in Public Policy at the University of Maryland afforded her an appreciation for how theory is implemented through regulation. As a result, she is able to support our clients in understanding how CMS reimbursement policies can affect their businesses."
Emma's interest in health policy extends beyond her work hours. As a Steering Committee member for the DC Society of Health Policy Young Professionals, she plays an active role in strategic planning, outreach, and event coordination to engage young professionals in health policy across the DC area.
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Applied Policy welcomes fall intern class |
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Applied Policy recently welcomed two new interns: Catherine Chua and Kelsi Putnam.
A 2023 graduate of the University of Maryland, College Park, Catherine holds a Bachelor of Science in Public Health Science with a double minor in Public Leadership & Humanities, Health and Medicine. For her, an “Applied Policy internship is the perfect transition from college to the workplace.” Catherine has a special interest in promoting health equity and expects that her work with Applied Policy will add to her understanding of the intersection of public health and health policy. She is especially interested in learning more about Medicare and Medicaid policy processes.
Kelsi, who completed her Bachelor of Arts in Public Policy with a minor in Public Health at William & Mary earlier this year, believes that “everyone should have access to quality and affordable healthcare.” Recognizing the importance of health policy in shaping individual’s health landscapes, she looks forward to learning from the Applied Policy team. She also noted that she is excited to be working so close to policymakers in DC (and we wouldn't be surprised to find the ultimate Frisbee fan, who played on a club team in college, on the National Mall in her spare time).
We are happy to have Catherine and Kelsi onboard and look forward to working with them in the coming months.
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Diagnostic testing is evolving
How can government keep up?
Join NVHPF on
Tuesday, October 24,
for our panel on diagnostic testing
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Diagnostic tests continue to rapidly evolve, allowing healthcare professionals to deliver personalized, precise, and expeditious results to their patients. Nevertheless, government agencies responsible for regulating and reimbursing these cutting-edge technologies often appear to lag behind. What measures can be implemented to ensure accessible and affordable access to novel diagnostic tools, while simultaneously sustaining incentives for the companies investing in their development?
Join the Northern Virginia Health Policy Forum on Tuesday, October 24 from noon to 1PM ET to hear a panel of experts discuss informed options for a path forward that will benefit the entire healthcare community.
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Highlights from NVHPF's Fall Media Panel
What's Next in Healthcare?
The Defining Trends to Follow
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On September 19, Michelle Stein, Health Care Editor, Reporter, and Assistant Publisher at Inside Health Policy; Rachana Pradhan, Correspondent at KFF Health News; and Shannon Firth, Washington Correspondent at MedPage Today joined the Northern Virginia Health Policy Forum to share their insights on key issues in healthcare.
Applied Policy's CEO Jim Scott moderated the wide-ranging conversation.
Each of the panelists noted that they will be carefully watching CMS's drug price negotiations with pharmaceutical companies and following associated lawsuits. Other key topics included Congress's review of pharmacy benefit manager programs, the healthcare workforce shortage, and the possibility of linking physician pay rates to inflation.
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Watch highlights of the event above,
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October 9-11
October 17-18
October 18
October 23-25
November 2-3
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Under review/On the docket |
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Applied Policy is following these rules under review at the Office of Management and Budget:
- Occupational Exposure to COVID-19 in Healthcare Settings
- Strengthening Oversight of Accrediting Organizations (AO) and Preventing AO Conflict of Interest, and Related Provisions (CMS-3367)
- Clinical Laboratory Improvement Amendments of 1988 (CLIA) Fees; Histocompatibility, Personnel, and Alternative Sanctions for Certificate of Waiver Laboratories (CMS-3326)
- CMS Enforcement of State Compliance with Reporting and Federal Medicaid Renewal Requirements Under Section 1902(tt) of the Social Security Act (CMS-2447)
- Contract Year 2025 Policy and Technical Changes to the Medicare Advantage, Medicare Prescription Drug Benefit, and Medicare Cost Plan Programs, and PACE (CMS-4205)
- HHS Notice of Benefit and Payment Parameters for 2025 (CMS-9895)
- Independent Dispute Resolution Operations (CMS-9897)
- Appeal Rights for Certain Changes in Patient Status (CMS-4204)
- Disclosures of Ownership and Additional Disclosable Parties Information for Skilled Nursing Facilities and Nursing Facilities (CMS-6084)
- Hospital Outpatient Prospective Payment System: Remedy for 340B-Acquired Drugs Purchased in Cost Years 2018-2023 (CMS-1793)
- CY 2024 Home Health Prospective Payment System Rate Update and Home Infusion Therapy Services Payment Update (CMS-1780)
- CY 2024 Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Medicare Part B
- CY 2024 Hospital Outpatient PPS Policy Changes and Payment Rates and Ambulatory Surgical Center Payment System Policy Changes and Payment Rates (CMS-1786)
Rules Cleared by OMB (Pending Release):
- Medicare Secondary Payer and Certain Civil Money Penalties (CMS-6061)
- Telemedicine Prescribing of Controlled Substances When the Practitioner and the Patient Have not had a Prior In-Person Medical Evaluation
See all rules under OMB review here.
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Bloomberg
Fierce Healthcare
MIT Technology Review
National Institutes of Health
U.S. Department of Justice
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Insight joke of the month for October |
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When should you take a cookie to your doctor? |
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October's book recommendation:
Algorithms to Live By,
The Computer Science of Human Decisions
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Are you perplexed as to how to choose the right apartment, employee, or life partner? We might have just the right book for you.
In Algorithms to Live By, Brian Christian, author of The Most Human Human, and Tom Griffiths, a professor of psychology and cognitive science at UC Berkeley, explain how algorithms developed for computers can be applied to human decision making.
Algorithms is well researched, with extensive chapter notes and an expansive bibliography. With advice on making order through sorting, when to think less, and what to forget, it provides valuable strategies for negotiating very human dilemmas. And, whether by design or accident, it serves as an engaging explanation of computer science.
At a time when artificial intelligence is blurring the lines between human and computer knowledge, you needn't worry that adopting principles of machine learning will have you approaching life with the cold logic of Mr. Spock. As The Guardian observed, “computing algorithms could be a surprisingly useful way to embrace the messy compromises of real, non-Vulcan life.”
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Applied Policy, L.L.C., is a health policy and reimbursement consulting firm strategically located minutes from Washington, D.C.
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